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© 2026 International In-house Counsel Journal Ltd. | ISSN 1754-0607 | Picture Credits: Freepix, Unsplash and by permission of the authors
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The Venezuelan Energy Pivot of 2026: Sovereignty Recalibrated, Sanctions Internalized, and the Emergence of Alignment Risk

February 2026SanctionsEnergy

Abstract

The 2026 restructuring of Venezuela’s hydrocarbon sector represents an unprecedented convergence of domestic legislative reform and extraterritorial regulatory conditioning. Following the January 3, 2026 political transition in Caracas and the installation of an Interim Administration, Venezuela enacted a sweeping reform of its Hydrocarbons Law dismantling the state-majority model entrenched since 2001. Simultaneously, the United States Treasury operationalized a layered sanctions-licensing framework (General Licenses 46A–50A) , integrating Venezuelan upstream activity into a compliance-centric hemispheric energy architecture. This Article examines the transformation from a sovereignty-maximizing petroleum regime to a conditional-access, alignment-based model. It analyses the contractual override of the Calvo doctrine , the contractualization of fiscal stability, the emergence of dual-jurisdiction operational risk, and the evolution of “country risk” into what practitioners must now conceptualize as “alignment risk”.

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Author

Haitao Zhang

General Counsel, Cnpc Latin America, Canada

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